15 PROVENANCE AND AUTHENTICITY – Food and Drink – Good Manufacturing Practice, 7th Edition

15
PROVENANCE AND AUTHENTICITY

Principle

The term ‘food provenance’ relates to not only the geographic elements of where the ingredients and the final food are grown, processed and finally manufactured, but also how that food is produced and whether the methods of production and processes employed comply with certain standards and protocols. Authentic products are those that demonstrate a given connection to a recipe, location or social characteristic. Authenticity is the innate quality of being authentic, genuine and of undisputed origin. It is essential for the food manufacturer to design, validate, implement and verify that adequate and appropriate systems are in place to ensure the provenance and authenticity of food ingredients and food products.

Background

15.1 Provenance as an innate characteristic relates to where and how ingredients are grown, caught and reared, the types of farming system employed (e.g. conventional, intensive, extensive, sustainable, organic, housed livestock, free‐range, genetically modified (GM), farmed or wild‐caught fish and so forth), the types of production or processing (e.g. traditional, home‐cured, oak‐matured etc.), the standards of people welfare said to have been complied with in the supply chain (e.g. Fairtrade, Ethical Trading Initiative Basecode, SEDEX) and relates specifically to the manufacturer’s geographic location and situation and the portfolio of materials used and products manufactured (e.g. local, seasonal, breed of livestock, specific crop variety etc.).

15.2 Food provenance can relate to a location, e.g. national or regional, down to a specific farm or field. Specific product claims and labelling will reflect this, such as country of origin (COO) labelling. Regulatory requirements with regards to COO labelling vary from country to country. The Food Information to Consumers’ (FIC) Regulation implements EU [European Union] Regulation No. 1169/2011 on the provision of food information to consumers. Regulation No. 1169/2011 identifies the origin of a food as being either its COO (see Articles 23 to 26 of Regulation (EEC) No. 2913/92) or its ‘place of provenance’. The term COO is defined in EU law by Articles 23 to 26 of EU Regulation No. 2913/92 establishing the Community Customs Code, being either:

  • Goods originating in a country shall be those wholly obtained or produced in that country, for example vegetable products harvested therein, live animals born and raised therein; and
  • Goods whose production involved more than one country shall be deemed to originate in the country where they underwent their last, substantial, economically justified processing or working in an undertaking equipped for that purpose and resulting in the manufacture of a new product or representing an important stage of manufacture.

Article 2(2)g of Regulation No. 1169/2011 states that a place of provenance is ‘a place where food is indicated to come from, and that is not a COO… [however] the name, business name or address of the food business operator on the label shall not constitute an indication of the COO or place of provenance of food within the meaning of the Regulation.’

15.3 The EU FIC Regulation requires origin indication for fresh, chilled and frozen meat derived from sheep, goats, poultry and pigs. Beef also requires this labelling but through separate legislation. If animals are born, reared and slaughtered in the same country then ‘reared in’ and ‘slaughtered in’ statements may be replaced by a single origin declaration. Where meat from different locations is packed together from separate member states within Europe and/or third countries all countries must be listed. Where meat is imported from third countries the term ‘non‐EU’ may be used.

15.4 The FIC legislation also requires that when the origin of a whole product is voluntarily identified that the origin of its primary ingredient, where it is different in terms of origin, must also be given, e.g. ‘Made in the UK with New Zealand lamb’. A primary ingredient is one that represents more than 50% of that food or which is usually associated with the name of the food by the consumer and for which in most cases a quantitative indication is required (see Article 2(2) (q) of EU Regulation No. 1169/2011).

15.5 Usually, unless there is specific legislation that states otherwise, COO or place of provenance identification is only mandatory if its absence would mean that the consumer might be misled as to the true origin of the manufactured/processed food. Origin labelling is mandatory for certain products in the EU under specific product legislation rather than the aforementioned FIC legislation. These products include fish, virgin and extra‐virgin olive oils, unprocessed beef and beef products, prepacked poultry meat from third countries, honey, fruit and vegetables.

Traditional and Regional Food

15.6 Traditional and regional food is prepared and made in a defined way, often using local ingredients. In the EU there are three indications of provenance for regional products with a given traditional or speciality heritage through the so‐called EU Protected Food Name Scheme (EUPFN). The EUPFN is covered by EU Regulation No. 1151/20121 and was introduced in Europe via EU Regulations Nos. 2081/92 and 2082/92 of 14 July 1992 defining the standards for a designation under different collective trademarks in 1993. The three categories are:

  • Protected Geographic Indication (PGI): This designates products which must be produced, processed or prepared within the geographical area and have a reputation, features or certain qualities attributable to that area. At least one of the stages of preparation or processing or production must take place in that area. Examples are Scotch Beef, Arbroath Smokie, Welsh Lamb and Cornish Pastie.
  • Traditional Speciality Guaranteed (TSG): This identifies products which are traditional, e.g. a recipe or production method, or have customary names and have a set of features which distinguish them from other similar products. These features are not due to the geographical area the product is produced in nor entirely based on technical advances in the method of production.
  • Protected Designation of Origin (PDO): This mark identifies agricultural products and foods which are produced, processed and prepared in the same geographic area, e.g. Shetland Lamb and Anglesey Sea Salt.

15.7 Foods that are labelled under the EUPFN scheme could be vulnerable to food integrity threats such as imitation or mislabelling, especially where there is a price differential between the PGI products and other seemingly identical products that do not carry that status. Manufacturers that produce or use these products as ingredients need to be aware of this threat to integrity and develop a countermeasures programme through their food integrity management system or FIMS (see Chapters 5 to 7).

15.8 Where specific claims are made with regard to the manufactured product it is important that there is full traceability of the ingredients or the product itself, i.e. it may come from a designated provenance, or has a designated identity or assurance status, e.g. Fairtrade, organic, COO. The organisation must have a suitable identification and traceability procedure in place to demonstrate the status of raw materials, in‐process material and finished product (see Chapter 14). Records should be maintained to demonstrate that the finished product complies with the legal requirements associated with such claims.

15.9 The terms ‘authentic’ and ‘authenticity’ are not as easy to define. Authenticity can relate to both intrinsic and extrinsic quality attributes (Chapter 2). Other terms have been used, such as iconic attributes or characteristics, i.e. those that relate to an object or event, and indexical attributes, which are characteristics that relate to facts or traditions. Often these attributes are distilled for consumers into terms such as traditional or artisan. It is important that such terms are suitably underpinned by records held by the manufacturer.

Note